The 2013 Action Plan on Base Erosion and Profit Shifting (the BEPS Action Plan) identified treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns. Jacques Sasseville and Edward Barret look at the work done to counter the unintended uses of tax treaties in an international context.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
While UN proposals to shift airline taxation from a residence-based system to a source-state one are not set in stone, ex-British Airways CEO Willie Walsh warns they would increase costs and complexity
Von Wobeser y Sierra’s head of tax shares best practices for resolving tax controversy and touts his firm’s founding partner as an exemplar of legal practice
Experts from law firm Kennedys outline the key tax disputes trends set to define 2026, ranging from increased enforcement to continued tariff drama and AI usage
They also warned against an ‘unnecessary duplication of efforts’ in UN tax convention negotiations; in other news, White & Case has hired Freshfields’ former French tax head
Defending loss situations in TP is not about denying the existence of losses but about showing, through proactive measures, that the losses reflect genuine commercial realities